Comment Log Display

On behalf of the City of San Pablo, I thank you and your agency for
its efforts to address how to effectively allocate Cap and Trade
revenue, and would like to provide some recommendations.

The City of San Pablo has put forward many policy initiatives that
strengthen our efforts to mitigate climate change. As a city we are
planning for and building out transit oriented development and
infill housing, we have many successful city initiatives supporting
efforts to improve public health and environmental quality, and we
have recently cleaned up brownfields and turned them into
productive sites.

As the California Environmental Protection Agency moves forward
with the CalEnviroScreen (CES) version 2.0, we are very concerned
that the formulas used may not support our efforts to provide
services to disadvantaged communities in San Pablo, Contra Costa
County, and the entire East Bay region.  We observe that CES 2.0
overlooks a large number of urban communities that are some of the
most polluted and disadvantaged in the State and the neighborhoods
that surround them. According to the Metropolitan Transportation
Commission, San Pablo is a Community of Concern, a defined minority
and low-income community. Low-income populations, defined if 30% or
more of the households earn below 200% of the poverty level and if
70% or more of the persons in the households were African American,
Asian American, Hispanic or Latino.

The City of San Pablo respectfully recommends the inclusion of
criteria regarding projects adjacent to disadvantaged census tracts
or a priority focus for projects in the same ZIP code that serve
disadvantaged neighborhoods. This change would significantly help
disaggregate poverty while serving the most impoverished in the
East Bay. For example, San Pablo shares a border with Richmond.
There are zip codes encompassing both cities, have many high risks
factors, such as poverty, poor air quality, and unemployment. 
However, the adjacent census tract does not account for many of
those residents needing services offered in San Pablo.

Given these facts, we request that the following steps be taken to
avoid CES 2.0 unfairly impacting Bay Area disadvantaged
communities:
	
1.	CES 2.0 not be used for funding allocations until flaws
identified by regional agencies have been corrected.
2.	Funds be initially apportioned by regional populations and then
allocated within the region by equitable tools to delineated
disadvantaged communities and adjacent communities serving them. 
3.	A new public workshop be held later in September or October
incorporating discussion of alternatives to CES 2.0.

Thank you.